BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the of San Diego Gas and Electric Company for a Certificate of Public Convenience and Necessity Authorizing the Construction of the for the Otay Mesa Power Purchase Agreement Transmission Project Application OPENING COMMENTS OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION ON THE PROPOSED DECISION OF ALJ BROWN Charles F. Robinson, General Counsel Sidney M. Davies, Senior Regulatory Counsel Grant A. Rosenblum, Regulatory Counsel California Independent System Operator 151 Blue Ravine Road Folsom, CA Telephone: Facsimile: Dated: June 16, 2005 Attorneys for the California Independent System Operator
2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the of San Diego Gas and Electric Company for a Certificate of Public Convenience and Necessity Authorizing the Construction of the for the Otay Mesa Power Purchase Agreement Transmission Project Application OPENING COMMENTS OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION ON THE PROPOSED DECISION OF ALJ BROWN In accordance with Rule 77.2 of the Commission s Rules of Practice and Procedure, the California Independent System Operator Corporation ( CAISO ) submits the following comments on the Proposed Decision ( PD ) of Administrative Law Judge ( ALJ ) Brown. The CAISO supports the PD s approval of San Diego Gas & Electric Company s ( SDG&E ) application for a Certificate of Public Convenience and Necessity ( CPCN ) for the construction of the Otay Mesa Power Plant Transmission Project ( Transmission Project ). The PD found that the Transmission Project is the appropriate upgrade to realize the full potential of Otay Mesa for grid reliability and [Reliability Must Run ( RMR )] savings, to reduce congestion and to provide for expansion capability for load growth. (PD at 61.) This finding is consistent with the conclusions reached by the CAISO. Equally important and as noted by the PD, the CAISO performed a thorough analysis of alternative electrical solutions prior to selecting the Transmission Project as the superior upgrade to achieving the benefits of the Otay Mesa Generating Plant. Accordingly, given the PD s acknowledgment that the Commission determined in Decision that the construction of the Otay Mesa 1
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5 MANATT, PHELPS & PHILLIPS, LLP DAVID L. HUARD WEST OLYMPIC BOULEVARD LOS ANGELES, CA MANATT, PHLEPS & PHILLIPS, LLP RANDALL W. KEEN WEST OLYMPICS BLVD. LOS ANGELES, CA CENTRE CITY DEVELOPMENT CORPORATION ALEXANDRA ELIAS 225 BROADWAY, SUITE 1100 SAN DIEGO, CA SAN DIEGO GAS & ELECTRIC COMPANY E. GREGORY BARNES 101 ASH STREET SAN DIEGO, CA PORT OF SAN DIEGO WILLIAM J. BRIGGS 3165 PACIFIC HIGHWAY SAN DIEGO, CA SAN DIEGO GAS & ELECTRIC CHRIS BING 8330 CENTURY PARK COURT, CP SAN DIEGO, CA LUCE, FORWARD, HAMILTON & SCRIPPS, LLP JOHN W. LESLIE EL CAMINO REAL, SUITE 200 SAN DIEGO, CA CALIFORNIA PUBLIC UTILITIES COMMISSION NOEL A. OBIORA SAN FRANCISCO, CA ALCANTAR & KAHL, LLP EVELYN KAHL 120 MONTGOMERY STREET, SUITE 2200 SAN FRANCISCO, CA GOODIN, MACBRIDE, SQUERI, RITCHIE & DAY BRIAN T. CRAGG 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA DUKE ENERGY AMERICAS JANE A. PEARSON 5400 WESTHEIMER COURT HOUSTON, TX DAVIS WRIGHT TREMAINE LLP JEFFREY P. GRAY ONE EMBARCADERO CENTER, SUITE 600 SAN FRANCISCO, CA HANNA AND MORTON LLP NORMAN A. PEDERSEN 444 SOUTH FLOWER STREET, SUITE 1500 LOS ANGELES, CA CALIFORNIA INDEPENDENT SYSTEM OPERATOR GRANT A. ROSENBLUM 151 BLUE RAVINE ROAD FOLSOM, CA GOODRICH ASG MIKE HARRINGTON MAIL ZONE 54/A LAGOON DRIVE CHULA VISTA, CA mike.harrington@goodrich.com ALBERT YORK HUANG 401 MILE OF CARS WAY, STE. 310 NATIONAL CITY, CA DUDEK & ASSOCIATES, INC. JOHN PORTEOUS 605 THIRD STREET SAN DIEGO, CA jporteous@dudek.com EUCALYPTUS HILLS LANDOWNERS ASSOC. INC. PO BOX 803 LAKESIDE, CA EHLA@flash.net ARLEN & ELAINE WATT OAK CREEK DRIVE LAKESIDE, CA SAN DIEGO GAS & ELECTRIC COMPANY THEODORE E. ROBERTS 101 ASH STREET, HQ 13D SAN DIEGO, CA troberts@sempra.com SAN DIEGO CONVENTION CENTER CORPORATION FRED SAINZ 111 W. HARBOR DRIVE SAN DIEGO, CA SAN DIEGO GAS & ELECTRIC CENTRAL FILES 8330 CENTURY PARK COURT, CP31-E SAN DIEGO, CA centralfiles@semprautilities.com SOUTHERN CALIFORNIA EDISON COMPANY BRUCE FOSTER 601 VAN NESS AVENUE, STE SAN FRANCISCO, CA bruce.foster@sce.com CALIFORNIA ENERGY MARKETS 517-B POTRERO AVE. SAN FRANCISCO, CA cem@newsdata.com PACIFIC GAS AND ELECTRIC COMPANY LAW DEPARTMENT FILE ROOM PO BOX 7442 SAN FRANCISCO, CA cpuccases@pge.com CALPINE CORPORATION MITCH WEINBERG 4160 DUBLIN BLVD. DUBLIN, CA mitchw@calpine.com CALPINE CORPORATION RICHARD L. THOMAS 4160 DUBLIN BLVD. DUBLIN, CA rickt@calpine.com CALPINE CORPORATION STEVEN S. SCHLEIMER 4160 DUBLIN BLVD. DUBLIN, CA sschleimer@calpine.com BINGHAM MC CUTCHEN GEOFFREY ROBINSON 1333 NORTH CALIFORNIA BLVD. WALNUT CREEK, CA geoffrey.robinson@bingham.com DUKE ENERGY ANDREW TRUMP PO BOX OAKLAND, CA altrump@duke-energy.com
6 MRW & ASSOCIATES, INC HARRISON STREET, SUITE 1440 OAKLAND, CA CALIFORNIA ISO 150 BLUE RAVINE ROAD FOLSOM, CA DUKE ENERGY NORTH AMERICA MELANIE GILLETTE 980 NINTH STREET, SUITE 1420 SACRAMENTO, CA VIEWPOINT WEST CHRISTINE KELLER GOVERNMENT SPRINGS ROAD MONTROSE, CO Carol A Brown ROOM 5103 cab@cpuc.ca.gov SCHEVERMAN CONSULTING PAUL SCHEVERMAN 3915 RAWHIDE ROAD ROCKLIN, CA pgs@ieee.org Maxine Harrison 320 WEST 4TH STREET SUITE 500 LOS ANGELES, CA omh@cpuc.ca.gov Julie A Fitch ROOM 5203 jf2@cpuc.ca.gov CALIFORNIA ENERGY COMMISSION CLARE LAUFENBERG TH ST., MS 46 SACRAMENTO, CA claufenb@energy.state.ca.us Billie C Blanchard AREA 4-A bcb@cpuc.ca.gov Scott Logan ROOM 4209 sjl@cpuc.ca.gov CALIFORNIA ENERGY COMMISSION KAREN GRIFFIN TH STREET, MS 39 SACRAMENTO, CA kgriffin@energy.state.ca.us
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